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V2920-16 23 June 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducción por i+d+i

CDTI report is binding for R&D classification and enables tax deduction

A company inquired whether a CDTI certification was sufficient to substantiate R&D+i tax deductions for Corporate Tax purposes. The DGT ruled that the CDTI report is binding for the Administration and that the R&D classification applies to the entire project without the need for annual renewal.

The question raised

1. Whether the certification from the CDTI, together with the documentation of invoices and other supporting documents audited by said Center, constitutes sufficient documentation to prove the classification of the project as an activity capable of generating the right to the R&D&i deduction for Corporate Income Tax.

The DGT's ruling

The reasoned report from the CDTI is binding for the Tax Administration regarding the classification of activities as research and development. Once the competent body classifies the project, such consideration extends to the entire developed project, without the need to perform the classification at the end of each year, provided that the notified conditions are met. The deduction base is composed of the direct expenses incurred during the period, reduced by the subsidies received.

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